News Disney v MiniMax Motions Dismiss 2026

On April 13, 2026, defendants in the copyright infringement lawsuit Disney Enterprises, Inc. et al. v. MiniMax et al.<ref name="docket">Justia Docket: Disney Enterprises, Inc. v. MiniMax, No. 2:2025cv08768 (C.D. Cal.)</ref> filed motions to dismiss, raising questions about personal jurisdiction, copyright registration of characters, and secondary liability for AI-generated content. A hearing on the motions is scheduled for May 29, 2026.<ref name="mckool">McKool Smith: In Minimax Suit, Nanonoble Moves to Dismiss Disney's Copyright Claims</ref><ref name="mishcon">Mishcon de Reya, Generative AI IP Cases and Policy Tracker</ref>

Background

Disney and 11 other plaintiffs filed the lawsuit on September 16, 2025, alleging that Hailuo AI, operated by Chinese company MiniMax (brand name) with entities including Shanghai Xiyu Jizhi Technology (SXJT) and Nanonoble, "pirates and plunders Plaintiffs' copyrighted works on a massive scale" by generating infringing images and videos of copyrighted characters.<ref name="disney_complaint">IPWatchdog: Disney Alleges Chinese AI Company's Copyright Infringement Is Willful and Brazen</ref>

The complaint alleged that users could submit text prompts requesting images of characters like Darth Vader, Spider-Man, the Simpsons, Batman, the Joker, and Superman, and Hailuo AI would generate high-quality, downloadable infringing content.<ref name="disney_complaint" /> Disney sought statutory damages of up to $150,000 per infringed work and permanent injunctive relief.<ref name="disney_complaint" />

Motions to Dismiss

MiniMax and SXJT Motion (12(b)(2))

MiniMax and SXJT filed a motion to dismiss for lack of personal jurisdiction, arguing that MiniMax is not a legal entity but merely a brand name, and therefore the court cannot exercise jurisdiction over it. Regarding SXJT, the motion contends that the court lacks personal jurisdiction because SXJT is a Chinese company that has not directed activities to the United States, with any U.S. contacts stemming from Nanonoble rather than SXJT itself.<ref name="mckool" /><ref name="mckool2">McKool Smith: Minimax and SXJT Move to Dismiss for Lack of Personal Jurisdiction</ref>

Nanonoble Motion (12(b)(6))

Nanonoble filed a motion to dismiss for failure to state a claim, raising four distinct arguments:<ref name="mckool" /><ref name="mishcon" /><ref name="chatgptiseatingtheworld">ChatGPTIsEatingTheWorld: Nanonoble Moves to Dismiss Disney Copyright Claims</ref>

1. Copyright Registration and Protectability: Nanonoble argues that Disney has not demonstrated it registered copyrights on individual characters as opposed to the works containing them, and that Disney may be unable to copyright characters under Ninth Circuit law.<ref name="mckool" />

2. Extraterritorial Training: Nanonoble contends that any copying related to direct infringement did not occur in the United States because the AI models were trained in China, placing the conduct outside the reach of the U.S. Copyright Act under the prohibition on extraterritorial application established in Subafilms, Ltd. v. MGM-Pathe Communications Co.<ref name="chatgptiseatingtheworld" /><ref name="mckool" />

3. No Direct Infringement from Plaintiff-Generated Outputs: Nanonoble argues that Disney's own generation of 52 allegedly infringing videos via Hailuo AI does not constitute infringement, citing the principle that "a copyright owner cannot infringe its own copyright" (Richmond v. Weiner, 353 F.2d 41 (9th Cir. 1965)).<ref name="chatgptiseatingtheworld" /><ref name="mckool" />

4. No Secondary (Contributory/Induced) Infringement: Nanonoble argues that Disney's contributory infringement claims fail the Cox Communications test—there was no tailoring to infringement or affirmative inducement of users, and Disney did not plausibly allege encouragement of infringement.<ref name="chatgptiseatingtheworld" /><ref name="mckool" /><ref name="copyrightlately">Copyright Lately: Cox v. Sony Music and AI Copyright Minimax</ref>

Nanonoble acknowledged that Disney also provided organic evidence of third-party infringement, including subscriber-posted Instagram videos and third-party posts across Reddit, TikTok, and YouTube.<ref name="mckool" />

Procedural Schedule

April 24, 2026: Filing deadline for motions to dismiss<ref name="chatgptiseatingtheworld" /><ref name="mckool" />
April 29, 2026: Opening briefs due for status conference<ref name="mckool" />
May 4, 2026: Opposition briefs due<ref name="mckool" />
May 5, 2026: Joint dispute chart due<ref name="mckool" />
May 12, 2026: In-person status conference before Magistrate Judge Wang<ref name="mckool" />
May 29, 2026: Hearing on motions to dismiss<ref name="copyrightlately" /><ref name="docket" />

Significance

The case is one of the first major copyright infringement lawsuits by Hollywood studios against a Chinese AI company, raising novel questions about:

Whether AI-generated character images constitute direct copyright infringement
Whether training AI models on copyrighted works outside the United States falls within U.S. copyright law (extraterritoriality)
Whether platform operators can be held secondarily liable for user-generated AI content, particularly after the Supreme Court's Cox Communications decision
Whether copyright holders can generate their own infringing content using the defendant's tool and then sue for it
Personal jurisdiction over Chinese AI companies whose products are used in the U.S. but whose entities and training occur abroad

Case Information

Court: U.S. District Court for the Central District of California (Case No. 2:25-cv-08768)
Judge: Judge Blumenfeld, Jr.
Plaintiffs: Disney Enterprises, Inc., Lucasfilm Ltd., Twentieth Century Fox Film Corp., Warner Bros. Entertainment Inc., DC Comics Inc.
Defendants: MiniMax (brand name), Hailuo AI, Shanghai Xiyu Jizhi Technology (SXJT), Nanonoble

References